Sana Hazina Butler v. Fidelity Management & Research Company LLC
S.D. New York · May 22, 2026
- Jurisdiction
- federal
- Court
- S.D. New York
- Record ID
- sana-hazina-butler-v-fidelity-management-research-company-llc-2026-05-22
- Observed outcome
- The Court issued a formal warning to the plaintiff regarding the submission of false legal authority.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Court issued a formal warning to a pro se litigant for submitting false legal citations. The Magistrate Judge admonished the plaintiff that presenting inaccurate case law is sanctionable conduct, regardless of whether the errors were caused by artificial intelligence or other factors, and warned that future non-compliance could lead to formal sanctions.
The Court reasoned that the presentation of false citations, quotations, and holdings is sanctionable conduct that abuses the adversary system, necessitating a formal warning to ensure future submissions contain only accurate representations.
This case illustrates judicial oversight of pro se filings involving potentially AI-generated or hallucinated legal authority. It reinforces that courts hold litigants responsible for the accuracy of their submissions, regardless of the underlying cause of the error.
Failure modes and consequences
- Pro Se
- Misrepresented Authority
- Other
- Trial
- Warning
- AI attribution
- Alleged
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Order issued by Magistrate Judge following a status conference regarding discovery stays and the plaintiff's submission of inaccurate legal authority.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The Court noted the plaintiff denied using AI, but referenced the possibility of AI or other mistakes.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify all legal citations against primary sources to ensure accuracy of case names, citations, and holdings.
- Implement rigorous review protocols for all filings to detect and correct potential hallucinations or mischaracterizations of authority.
- Maintain documentation of research processes to ensure accountability for the accuracy of legal arguments presented to the court.